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30 August 1990 Income Tax Severed Letter ACC9246 - Calculation of Gains Exclusion in Canada-U.S. Income Tax Convention

Income Tax Convention 24(1) 900875 G. Aresenault Attention: 19(1) August 30, 1990 Dear Sirs: Re: Calculation of Gains Exclusion in Article XIII of the Canada-U.S. 1980 Tax Convention This is in reply to your reply to your letter dated may 15, 1990. We do not agree with your interpretation of paragraph 9 of Article XIII of the Canada-United States Income Tax Convention, 1980 (the "Treaty"). ...

28 January 1993 Income Tax Severed Letter 9229456 F - Convention Canada-France—Artistes incorporés

Claude Lemelin réorganisations Chef de l'Administration des des corporations conventions fiscales (613) 957-2127 A l'attention de M. ... La convention fiscale entre le Canada et la France (ainsi que celle entre le Québec et la France) confirme par ailleurs que ces revenus sont imposables dans le pays où les prestations artistiques ou sportives sont rendues (article 17 de la convention). Les conventions fiscales sont toutefois muettes en ce qui concerne les modalités de l'imposition. 6. ...

23 March 1990 Income Tax Severed Letter ACC9206 - Canada-Sweden Income Tax Convention on Pensions

23 March 1990 Income Tax Severed Letter ACC9206- Canada-Sweden Income Tax Convention on Pensions Unedited CRA Tags Canada-Sweden Tax Treaty:Art. 18:1 19(1) Jim Wilson (613) 957-2063 HBW 4000-2 HBW 4125-S7 EACC9206 March 23, 1990 19(1) We are writing in reply to your letter dated March 15, 1990, concerning the tax treatment of certain pensions received from Sweden. Pursuant to Article 18, paragraph 1 of the Canada-Sweden Income Tax Convention, pensions arising in Sweden and paid to a resident of Canada may be taxed in both Sweden and Canada. ...

21 September 1989 Income Tax Severed Letter ACC8674 F - Canada-Netherlands Income Tax Convention

21 September 1989 Income Tax Severed Letter ACC8674 F- Canada-Netherlands Income Tax Convention Unedited CRA Tags 56(1)(a), 110(1)(f)(i), 126(1)(b)(ii)(A)(III) 19(1) HBW 4125-N1 Jim Wilson (613) 957-2063 September 21, 1989 Dear 19(1): We are writing in reply to your letter of August 17, 1989, concerning the Canada-Netherlands Income Tax Convention. ...

16 February 1988 Income Tax Severed Letter 5-2547 - [Canada-Brazil Income Tax Convention (the "Treaty")]

16 February 1988 Income Tax Severed Letter 5-2547- [Canada-Brazil Income Tax Convention (the "Treaty")] February 16, 1988 M.M. Trotier (613) 957-9795 Dear Sir: Re: Canada-Brazil Income Tax Convention (the "Treaty") This is in reply to your letter dated November 17, 1986 concerning tax sparing under Article 22 of the Treaty. ...

4 April 1990 Income Tax Severed Letter AC59689 - Canada-U.S. Income Tax Convention - Withholding Tax on RRIF Payments

Income Tax Convention- Withholding Tax on RRIF Payments M. Shea-DesRosiers (613) 957-8953 19(1) April 4, 1990 Dear Sirs: Canada-U.S. Income Tax Convention ("U.S. Treaty") Withholding Tax on Payments Made under a Registered Retirement Income Fund ("RRIF") This is in reply to your letter of February 28, 1990 concerning the applicable withholding tax rate to payments made under an RRIF to a resident of the United States. ...

9 May 1989 Income Tax Severed Letter 5-7189 - [Canada-U.S. Income Tax Convention (1980) (the "Treaty") Article XIII, Paragraphs 2 and 4 Disposition of a Partnership Interest]

Income Tax Convention (1980) (the "Treaty") Article XIII, Paragraphs 2 and 4 Disposition of a Partnership Interest] Revenue Canada Taxation Head Office XXXX D.Y. ... Income Tax Convention (1980) (the "Treaty") Article XIII, Paragraphs 2 and 4 Disposition of a Partnership Interest This is in reply to your letter of December 2, 1988 concerning our interpretation of the Treaty in respect of the disposition by a U.S. resident of an interest in a partnership conducting operations in Canada through a permanent establishment where the partnership interest is not real property. ...

31 January 1992 Income Tax Severed Letter 9131325 - Partnerships and the Canada-U.S. Income Tax Convention

Income Tax Convention Unedited CRA Tags Canada–U.S. Tax Convention Canada-U.S. ... Income Tax Convention (1980) (the "Treaty") and Partnerships This is in response to your letter dated November 6, 1991 wherein you requested the Department's interpretation of certain treaty provisions under a hypothetical set of facts. ...

22 January 1987 Income Tax Severed Letter 7-1425 - [Article IV, Canada-U.S. Income Tax Convention, 1980 (the "Treaty")]

Income Tax Convention, 1980 (the "Treaty")] January 22, 1987 Specialty Rulings Directorate G. ... Income Tax Convention, 1980 (the "Treaty") We are returning the six (6) unassessed 1985 returns included with your Round Trip Memorandum ("RTM") of January 7, 1987 concerning an individual's residency status pursuant to the income Tax Act (the "Act") and pursuant to the "tie breaker" rules in Article IV of the Treaty. ... Rather, since the opening words of Article IV read "For the purposes of this convention", those residency rules are relevant only for the purposes of determining the extent to which another Article of the Treaty might exempt certain income from Canadian Tax. ...

27 February 1987 Income Tax Severed Letter 5-2777 - [Article XVIII (Pensions and Annuities) of the Canada-U.S. Income Tax Convention.]

Income Tax Convention.] K.B. Harding (613) 957-2129 February 27, 1967 Dear Sirs: This is in reply to your letter of January 26, 1987 concerning Article XVIII (Pensions and Annuities) of the Canada-U.S. income Tax Convention. ... Income Tax Convention includes all amounts received upon or after retirement in recognition of service in an office or employment. ...

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